Applying these principles, the Karnataka, Meghalaya and Nagaland

proclamations were invalidated. In the case of Karnataka, the Court

ruled that the question of lack of majority support for the Ministry was
not tested on the floor of the House and the Governor’s report was
suggestive of mala fides and the proclamation based on such report
was also mala fides and thus, was struck down.
The case of proclamations issued in the case of Madhya Pradesh,
Rajasthan and Himachal Pradesh was a little different as none of the
State Governments had lost their majority but the proclamations were
issued in the wake of disturbances after of incidents at Ayodhya on 6
December 1992. In this case, the Court emphasised that the various
constitutional provisions by implication prohibit the establishment of a
theocratic state and prevent the State from either identifying itself with
or favouring any particular

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Bommai challenged the validity of the proclamation before the High
Court of Karnataka but the Court dismissed the petition holding that
the facts stated in the Governor’s report could not be held to be
irrelevant and also held that the floor test was neither mandatory nor
obligatory & was not a prerequisite to sending of report to the
President. Bommai appealed to the

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